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INDICTM IINT
'I hc (trend Jury for the District of Columbia charges: Case: 1:17
cr-00201
Assigned To . Judge Jackson, Amy Berman
Introduction Assign. Date: 10/27/201 7
Description INDICTMENT (B)
At al 1 times relevant to this Indictment:
l. Dcf c ndants PAUL J. MANAFORT, JR., (MANAIr(>8:I) and RICHARD W. (rA'I'ES tll
((rATES) served for years as political consultants and lobbyists Bctwcc al. least 2006 and 2015,
MANAFOR'I' and (IA'f ES acted as unrcgistcred agents ot'thc Govct'lltllcnt of Ilkraine, ttte Ptuty
of Regions (a Ukrainian poJilical party whose leader Victor Yaukovych was I'resident front 201(l
to 2014), Yanuhoyych, and the Opposition Bloc (a successor to the Patty of Regions that framed
in 2014 when Yanukovych fled to Russia). MANAFORT and GATES generated tens of millions
of dollars in incotne as a result of their Ukraine work. In order to hide l.!kraine payrents fron;
United States authoritics, from approxitnatcly 2006 through at least 2016, lvIANAFOR'I' and
(lh'I ES laundered thc money through scores oi' United States and foreign corporations,
payments into foreign nominee companies and bank accounts, opened by them and their
accomplices in nominee names and in various foreign countries, including Cyprus, Saint Vincent
& the Grenadines (Grenadines), and the Seychelles. MANAFORT and GATES hid the existence
of the foreign companies and bank accounts, falsely and repeatedly reporting to their tax preparers
and to the United States that they had no foreign bank accounts,
3, In f u r therance of the scheme, MANAFORT and GATES concealed from the United States
their work as agents of, and millions of dollars in payments from, Ukraine and its political parties
and leaders. Because MANAFORT and GATES, among other things, directed a campaign to
lobby United States officials on behalf of the Government of Ukraine, the President of Ukraine,
and Ukrainian political parties, they were required by law to report to the United States their work
and fees. MANAFORT and GATES didnotdo so, Instead, whentheDepartmentof Justice sent
inquiries to MANAFORT and GATES in 2016 about their activities, MANAFORT and GATES
4, I n f ur t h erance of the scheme, MANAFORT used his hidden overseas wealth to enjoy a
lavish lifestyle in the United States, without paying taxes on that income. MANAFORT, without
reporting the income to his tax preparer or the United States, spent millions of dollars on luxury
goods andservices for himself and his extended. family through payments wired from offshore
nominee accounts to United States vendors. MA N A F ORT also used these offshore accounts to
purchase multi-million dollar properties in the United States. MANAFORT then borrowed
millions of dollars in loans using these properties as collateral, thereby obtaining cash in the United
States without reporting and paying taxes on the income. In order to increase the amount of money
he could access in the United States, MANAFORT defrauded the institutions that loaned money
on these properties so that they would lend him more money at more favorable rates than he would
was instrumental in opening. Like MANAFORT, GATES used money from these offshore
accounts to pay for his personal expenses, including his mortgage, children's tuition, and interior
6, In t o t al, more than $75,000,000 flowed through the offshore accounts. MANAFORT
launderedmore than $18,000,000, which was used by him to buy property,goods, and services in
the United States, income that he concealed from the United States Treasury, the Department of
Justice,
and others. GATES transferred more than $3,000,000 from the offshore accounts to other
7. MANA F ORT was a United States citizen, He resided in homes in Virginia, Florida, and
9. In 2 0 05, MANAFORT and another partner created Davis Manafort Partners, Inc. (DMP) to
engage principally in political consulting. DMP had staff in the United States, Ukraine, and
Russia. In 2011, MANAFORT created DMP International, LLC (DMI) to engage in work for
of Ukraine,the Party of Regions, and members of the Party of Regions. DMI was a partnership
solely owned by MANAFORT and his spouse. GATES worked for both DMP and DMI and
interests in Ukraine, including the election of its slate of candidates, In 2010, its candidate for
President, Yanukovych, was elected President of Ukraine. In 2014, Yanukovych fled Ukraine for
Russia in the wake of popular protests of widespread governmental corruption. Yanukovych, the
Party of Regions, and the Government of Ukraine were MANAFORT, DMP, and DMI clients.
11. T h e European Centre for a Modern Ukraine (the Centre) was created in or about 2012 in
Belgium as amouthpiece
for Yanukovych and the Party of Regions, The Centre was used by
MANAFORT, GATES, and others in order to lobby and conduct a public relations campaign in
the United States and Europe on behalf of the existing Ukraine regime. The Centre effectively
12. M A N A FORT and GATES owned or controlled the following entities, which were used in
Domestic Entities
C r i o t Entities
13, T h e Internal Revenue Service (IRS) was a bureau in the United States Department of the
Treasury responsible for administering the tax laws of the United States and collecting taxes owed
to the Treasury.
The Scheme
14. B e tween in or around 2008 and 2017, both dates being approximate and inclusive, in the
District of Columbia and elsewhere, MANAFORT and GATES devised and intended to devise,
and executed and attempted to execute, a scheme and artifice to defraud, and to obtain money and
property by means of false and fraudulent pretenses, representations, and promises from the United
States, banks, and other financial institutions, As part of the scheme, MANAFORT and GATES
repeatedly provided false information to financial bookkeepers, tax accountants, and legal counsel,
among others.
MANAFORT And GATES' Wirin O f M on e F r om Offshore Accounts Into The United States
15, I n o r der to use the money in the offshore nominee accounts of the MANAFORT-GATES
entities without paying taxes on it, MANAFORT and GATES caused millions of dollars in wire
transfers from these accounts to be made for goods, services, and real estate. They did not report
16. F r om 2008 to 2014, MANAFORT caused the following wires, totaling over $12,000,000,
to be sent to the vendors listed below for personal items, MANAFORT did not pay taxes on this
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Transaction Originating Account Country of AHlount of
Payee
Date Holder Origination Transaction
2/12/2013 Lucicle Consultants Limited Cyprus $3,300
United
7/15/2013 Pompolo Limited $13,325
Kingdom
11/26/2013 Global Endeavour Inc. Grenadines $9,400
ndor K Total $164,740
Vendor L 4/12/2012 Lucicle Consultants Limited Cyprus $83,525
(Payments 5/2/2012 Lucicle Consultants Limited Cyprus $12,525
Relating to three
Range Rovers) 6/29/2012 Lucicle Consultants Limited Cyprus $67,655
Vendor 0
(Purchase of 10/5/2012 Lucicle Consultants Limited Cyprus $62,7SO
Mercedes Benz)
17. I n 2012, MANAFORT caused the following wires to be sent to the entities listed below to
purchase the real estate also listed below. MANAFORT did not report the money used to make
18. I t is illegal to act as an agent of a foreign principal engaged in certain United States influence
activities without registering the affiliation, Specifically, a person who engages in lobbying or
public relations work in the United States (hereafter collectively referred to as lobbying) for a
foreign principal such as the Government of Ukraine or the Party of Regions is required to provide
a detailed written registration statement to the United States Department of Justice. The filing,
made under oath, must disclose the name of the foreign principal, the financial payments to the
lobbyist, and the measures undertaken for the foreign principal, among other information. A
person required to make such a filing must further make in all lobbying material a "conspicuous
statement" that the materials are distributed on behalf of the foreign principal, among other things.
The filing thus permits public awareness and evaluation of the activities of a lobbyist who acts as
19. I n f urtherance of the scheme, from 2006 until 2014, both dates being approximate and
inclusive, MANAFORT and GATES engaged in a multi-million dollar lobbying campaign in the
United States at the direction of Yanukovych, the Party of Regions, and the Government of
Ukraine. MANAFORT and GATES did so without registering and providing the disclosures
required by law,
20. A s p art of the scheme, in February 2012, MANAFORT and GATES solicited two
Washington, D.C., firms (Company A and Company B) to lobby in the United States on behalf of
Yanukovych,the Party of Regions, and the Government of Ukraine. For instance, GATES wrote
21. M A N A FORT repeatedly communicated in person and in writing with Yanukovych, and
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GATES passed on directions to Company A and Company B. For instance, MANAFORT wrote
Y anukovych memorandum
a dated April 8,2012,in w hich he provided Yanukovych an update on
the lobbying firms' activities "since the inception of the project a few weeks ago. It is my intention
to provide you with a weekly update moving forward." Toward the end of that first year, in
November 2012, GATES wrote to Company A and Company B that the firms needed to prepare
an assessment of their past and prospective lobbying efforts so the "President" could be briefed by
"Paul" "on what Ukraine has done well and what it can do better as we move into 2013,"
22. A t the direction of MANAFORT and GATES, Company A and Company B engaged in
extensive lobbying. Among other things, they lobbied multiple Members of Congress and their
staffs about Ukraine sanctions, the validity of U k raine elections, and the propriety of
Yanukovych's imprisoning his presidential rival, Yulia Tymoshenko (who had served as Ukraine
President prior to Yanukovych), MANAFORT and GATES also lobbied in connection with the
roH out of a report concerning the Tymoshenko trial commissioned by the Government of Ukraine.
MANAFORT and GATES used one of their offshore accounts to funnel $4 miHion to pay secretly
23. T o minimize public disclosure of their lobbying campaign, MANAFORT and GATES
arranged for the Centre to be the nominal client of Company A and Company B, even though in
fact the Centre was under the ultimate direction of the Government of Ukraine, Yanukovych, and
the Party of Regions. For instance, MANAFORT and GATES selected Company A and Company
B, and only thereafter did the Centre sign contracts with the lobbying firms without ever ineeting
either company, Company A and Company B were paid for their services not by their nominal
client, the Centre, but solely through off-shore accounts associated with the MANAFORT-GATES
entities, namely Bletilla Ventures Limited (in Cyprus) and Jeunet Ltd, and Global Endeavour Inc.
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(in Grenadines). In total, Company A and Company B were paid more than $2 million &om these
24. T o conceal the scheme, MANAFORT and GATES developed a false and misleading cover
storythatwould distance themselves and the Government of Ukraine, Yanukovych, and the Party
of Regionsfrom the Centre, Company A, and Company B, For instance,in the wake of extensive
press reports on MANAFORT and his connections with Ukraine, on August 16, 2016, GATES
o Q: "Can you describe your initial contact with[Company B] and the lobbying goals
A; "Our [MANAFORT and GATES'] task was to assist the [Centre] find
representation in Washington, but at no time did our firm or members provide any
e A: "The structure of the arrangement between the [Centre] and [Company A and
Compa
nyB] was worked out by the two parties,"
e Q: "Can you say where the funding from for [sic] the [Centre] came from? (this
amounted to well over a million dollars between 2012 and 2014)." A: "This is a
question better asked of the [Centre] who contracted with the two firms."
to Company B and/or the [Centre] as the agreement was between the parties. Our
firm did not play a role in the structure, nor were we registered lobbyists."
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Company B through a principal replied to GATES the same day that "there's a lot of email traffic
that has you much more involved than this suggests [.] We will not disclose that but heaven knows
25. In S e ptember 2016, after numerous recent press reports concerning MANAFORT, the
Department of Justice informed MAN A FORT, GATES, and DMI that it sought to determine
whether they had acted as agents of a foreign principal under the Foreign Agents Registration Act
(FARA), without registering, In November 2016 and February 2017, MANAFORT, GATES, and
DMI caused false and misleading letters to be submitted to the Department of Justice, which
mirrored the false cover story set out above. T h e l etters, both of w hich were approved by
MANAFORT and GATES before they were submitted, represented, among other things, that:
DMI's "efforts on behalf of the Party of Regions" "did not include meetings or
e MANAFORT and GATES did not "recall meeting with or conducting outreach
to U.S. governm
ent officials or U.S. media outlets on behalf of the [Centre], nor
do they r ecall b eing party t o , a r ranging, or f a cilitating any s uch
Gates and Manafort that such commimications would have been facilitated and
Company A and Company B to the Centre and provided the Centre with a list
DMI "does not retain communications beyond thirty days" and as a result of
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this policy, a "search has returned no responsive documents," The November
26. I n f act, MANAFORT and GATES had: selected Company A and Company B; engaged in
weekly scheduled calls and frequent emails with Company A and Company B to provide them
directions as to specific lobbying steps that should be taken; sought and received detailed oral and
written reports from these fiiTns on the lobbying work they had performed; communicated with
Yanukovych to brief him on their lobbying efforts; both congratulated and reprimanded Company
A and Company B on their lobbying work; communicated directly with United States officials in
connection with this work; and paid the lobbying firms over $2 million from offshore accounts
they controlled, among other things. In addition, court-authorized searches of MANAFORT and
GATES' DMI email accounts and MANAFORT's Virginia residence in July 2017 revealed
numerous documents, including documents related to lobbying, which were more than thirty-days
old at the time of the November 2016 letter to the Department of Justice.
27. U n i ted States citizens who have authority over certain foreign bank accounts whether or
not the accounts are set up in the names of nominees who act for their principals have reporting
28. F i r st, the Bank Secrecy Act and its implementing regulations require United States citizens
to repoit to the United States Treasury any financial interest in, or signatory authority over, any
bank account or other financial account held in foreign countries, for every calendar year in which
the aggregate balance of all such foreign accounts exceeds $10,000 at any point during the year,
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This is commonly known as a foreign bank account report or "FBAR." The Bank Secrecy Act
requires these repoits because they have a high degree of usefulness in criminal, tax, or regulatory
Network (FinCEN) is the custodian for FBAR filings, and FinCEN provides access to its FBAR
database to law enforcement entities, including the Federal Bureau of Investigation. The reports
filed by individuals and businesses are used by Iaw enforcement to identify, detect, and deter
money laundering that furthers criminal enterprise activity, tax evasion, and other unlawful
activities.
29. S e c o nd, United States citizens also are obligated to report information to the IRS regarding
foreign bank accounts. For instance, in 2010 Form 1040, Schedule B had a "Yes" or "No" box to
record an answer to the question: "At any time during [the calendar year], did you have an interest
in or a signature or other authority over a financial account in a foreign country, such as a bank
account, securities account, or other financial account?" If the answer was "Yes," then the form
required the taxpayer to enter the name of the foreign country in which the financial account was
located.
30. F o r e ach year in or about and between 2008 tlirough at least 2014, MANAFORT had
authority over foreign accounts that required an FBAR report. Specifically, MANAFORT was
required to report to the United States Treasury each foreign bank account held by the foreign
MANAFORT-GATES entities noted above in paragraph 12 that bear the initials PM. No FBAR
31. F o r each year in or about and between 2008 through at least 2013, GATES had authority
over foreign accounts that required an FBAR report. Specifically, GATES was required to report
to the United States Treasury each foreign bank account held by the foreign MANAFORT-GATES
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entities noted above in paragraph 12 that bear the initials RG, as well as three other accounts in
the United Kingdom. No FBAR reports were made by GATES for these accounts,
32. F i u thermore, in each of MANAFORT's tax filings for 2008 through 2014, MANAFORT
represented falsely that he did not have authority over any foreign bank accounts. MANAFORT
and GATES had repeatedly and falsely represented in writing to MANAFORT's tax preparer that
MANAFORT had n o a uthority over f oreign bank accounts, knowing that such false
representations would result in false MANAFORT tax filings. For instance, on October 4, 2011,
MANAFORT's tax preparer asked MANAFORT in writing: "At any time during 2010, did you
[or your wife or childrenj have an interest in or a signature or other authority over a financial
account in a f o r eign country, such as a bank account, securities account or other financial
account?" On the same day, MANAFORT falsely responded "NO." MANAFORT responded the
same way as recently as October 3, 2016, when MANAFORT's tax preparer again emailed the
question in connection with the preparation of MANAFORT's tax returns: "Foreign bank accounts
33. A f t er MANAFORT used his offshore accounts to purchase real estate in the United States,
he took out inortgages on the properties thereby allowing MANA FORT to have the benefits of
liquid income without paying taxes on it. Further, MANAFORT defrauded the banks that loaned
him the money so that he could withdraw more money at a cheaper rate than he otherwise would
34. I n 2 0 12, MANAFORT, through a corporate vehicle called "MC Soho Holdings, LLC"
owned by him and his family, bought a condominium on Howard Street in the Soho neighborhood
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in Manhattan, New York. He paid approximately $2,850,000. All the money used to purchase
the condominium carne f'rom MANAFORT entities in Cyprus. MANAFORT used the property
from at least January 2015 through 2016 as an income-generating rental property, charging
thousands of dollars a week on Airbnb, among other places, In his tax returns, MANAFORT took
35. I n late 2015 through early 2016, MANAFORT applied for a mortgage on the condominium.
Because the bank would permit a greater loan amount if the property were owner-occupied,
MANAFORT falsely represented to the bank and its agents that it was a secondary home used as
such by his daughter and son-in-law and was not a property held as a rental property. For instance,
on January 26, 2016, MANAFORT wrote to his son-in-law to advise him that when the bank
appraiser came to assess the condominium his son-in-law should "[r]emember, he believes that
you and [~ A FOR T ' s daughter] are living there." Based on a request &om MANAFORT,
GATES caused a document to be created which listed the Howard Street property as the second
home of MANAFORT's daughter and son-in-law, when GATES knew this fact to be false. As a
result of his false representations, in March 2016 the bank provided MANAFORT a loan for
approximately $3,185,000.
36. A l s o in 2012, MANAFORT -- through a corporate vehicle called "MC Brooklyn Holdings,
LLC" similarly owned by him and his family bought a brownstone on Union Street in the Carroll
G ardens sectionof Brooklyn, New York. He paid approximately $3,000,000 in cash for the
property, All of that money came from a ~ A PO R T entity in Cyprus, After purchase of the
single family home. In late 2015 through early 2016, MANAFORT sought to borrow cash against
the property. The institution MANAFORT went to for the loan provided greater loan amounts for
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"construction loans" that is, loans that required the loan amounts to be used to pay solely for
construction of the property and thus increase the value of the property serving as the loan's
collateral. The institution would thus loan money against the expected completed value of the
property, which in the case of the Union Street property was estimated to be $8,000,000. In early
2016, MANAFORT was able to obtain a loan of approximately $S,000,000, after promising the
bank that approximately $1,400,000 of the loan would be used solely for construction of the Union
Street property. H o wever, MANAFORT never intended to limit use of the proceeds to
construction as required by the loan contracts. In December 2015, before the loan was made,
MANAFORT wrote his tax preparer, among others, that the construction loan "will allow me to
pay back the [another Manafott apartment] mortgage in full.... " Further, when the construction
loan closed, MANAFORT used hundreds of thousands of dollars from the construction loan to
Statuto A l l e a t ions
COUNT ONE
(Conspiracy Against The United States)
38. F r om in or about and between 2006 and 2017, both dates being approximate and inclusive,
in the District of Cojumbia and elsewhere, the defendants PAUL J. MANAFORT, JR., and
RICHARD W. GATES III, together with others, knowingly and intentionally conspired to defraud
the United States by impeding, impairing, obstructing, and defeating the lawful governmental
functions of a government agency, namely the Department of Justice and the Department of the
Treasury, and to commit offenses against the United States, to wit, the violations of law charged
in Counts Three through Six and Ten through Twelve.
39. I n f urtherance of the conspiracy and to effect its illegal object, MANAFORT and GATES
committed the overt acts noted in Count Eleven and the overt acts, among others, in the District of
Columbia andelsewhere as set forth in paragraphs 9, 16, 17, 20-25, 32, and 34-36, which are
incorporated herein.
COUNT T%0
(Conspiracy To Launder Money)
41. I n o r around and between 2006 and 2016, both dates being approximate and inclusive,
within the District of Columbia and elsewhere, the defendants PAUI. 3, MANAFORT, JR., and
MCHARD W. GATES III, together with others, did knowingly and intentionally conspire to:
(a) transport, transmit, and transfer monetary instnunents and funds from places outside
the United States to and through places in the United States and from places in the United
States to and through places outside the United States, with the intent to promote the
violation of Title 22, United States Code, Sections 612 and 618(the "Specified Unlawful
Activity" ), contrary to Title 18, United States Code, Section 1956(a)(2)(A); and
(b) conduct financial transactions, affecting interstate and foreign commerce, knowing that
the property involved in the financial transactions would represent the proceeds of some
form of unlawful activity, and the transactions in fact would involve the proceeds of
Specified UnlawfLd Activity, knowing that such financial transactions were designed in
whole and in part (i) to engage in conduct constituting a violation of sections 7201 and
7206 ofthe Internal Revenue Code of 1986, and (ii) to conceal and disguise the nature,
location, source, ownership, and control of the proceeds of the Specified Unlawful
Activity, contrary to Title 18, United States Code, Section 1956 (a)(1)(A)(ii) and
1956(a)(1)(B)(i),
43. O n t h e filing due dates listed below, in the District of Coliunbia and elsewhere, the
defendant PAUL J. MANAFORT, JR., unlawfully, willfully, and knowingly did fail to file with
the Department of the Treasury an FBAR disclosing that he has a financial interest in, and signature
and other authority over, a bank, securities, and other financial account in a foreign country, which
had an aggregate value of more than $10,000, while violating another law of the United States and
as part o f pattern of illegal activity involving more than $100,000 in a 12-month period, during the
45. O n t h e filing due dates listed below, in the District of Columbia and elsewhere, the
defendant RICHARD W. GATES III unlawfully, willfully, and knowingly did fail to file with the
Department of the Treasury an FBAR disclosing that he has a financial interest in, and signature
and other authority over, a bank, securities, and other financial account in a foreign country, which
had an aggregate value of more than $10,000, while violating another law of the United States and
as part of pattern of illegal activity involving more than $100,000 in a 12-month period, during the
COUNT TKN
(Unregistered Agent Of A Foreign Principal)
47. F r o m in or about and between 2008 and 2014, both dates being approximate and inclusive,
within the District of Columbia and elsewhere, the defendants PAUL J. MANAFORT, JR., and
RICHARD W. GATES III knowingly and willfully, without registering with the Attorney General
as required by law, acted as agents of a foreign principal, to wit, the Government of Ukraine, the
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Party of Regions, and Yanukovych,
COURT KLKVKN
(False and Misleading FARA Statements)
49. O n or about November 23, 2016 and February 10, 2017, within the District of Columbia
and elsewhere, the defendants PAUL J, MANAFORT, JR,, and RICHARD W. GATES III
knowingly and willfully caused to be made a false statement of a material fact, and omitted a
material fact necessary to make the statements therein not misleading, in a document filed with
and furnished to the Attorney General under the provisions of PARA, to wi t the underlined
statements:
"[DMI 's efforts on behalf of the Part of Re ions and Opposition Bloc did not
" DMI did r ovide the Centre, attherequestofmembers ofthe Party of Regions,
Company B] for the Centre 's reference and further consideration, The Centre
within the United States for which these entities registered under the Lobbying
Disclosure Act."
"To Gates' recollection these effoits included rovidin olic b r i efin s to the
27
Ukraine includin a r tici ation in and/or coordination of related conference calls
and meetin s, Althou h Gates recalls interactin with the Centre 's consultants
re ardin efforts in the Ukraine and Euro e neither Gates nor Mr. Manafort recall
o utlets on behalf of the the Centre nor do the recall bein a r t t o arran in o r
have been facilitated and conducted b the Centre 's U.S. consultants as directed
e "[A se arch has been conducted for corres ondence containin additional
However as a result of DM I' s E mail Retention Polic w h ich does not retain
communications,"
COUNT TWELVK
(False Statements)
51. O n or about November 23, 2016 and February 10, 2017, within the District of Columbia
and elsewhere, in a matter within the jurisdiction of the executive branch of the Government of
the United States, the defendants PAUL J. MANAFORT, JR., and RICHARD W. GATES III
knowingly and willfully did cause another: to falsify, conceal, and cover up by a scheme and device
a material fact; to make a materially false, fictitious, and fraudulent statement and representation;
and to make and use a false writing and document knowing the same to contain a materially false,
fictitious, and fraudulent statement, to wit, the statements in the November 23, 2016 and February
FORFKITURK ALLEGATION
52, P u r s uant to Fed. R, Crim, P, 32.2, notice is hereby given to the defendants that the United
States will seek forfeiture as part of any sentence in accordance with Title 18, United States Code,
Sections 981(a)(1)(C) and 982(a)(1) and (a)(2), and Title 28, United States Code, Section 2461(c),
in the event of the defendants' convictions under Count Two of this Indictment. Upon conviction
of the offense charged in Count Two, the defendants PAUL J. MANAFORT, JR., and RICHARD
W. GATES III shall forfeit to the United States any property, real or personal, involved in such
offense, and any property traceable to such property, Upon conviction of the offenses charged in
Counts Ten and Eleven, the defendants PAUL J, MANAFORT, JR,, and RICHARD W. GATES
III shall forfeit to the United States any property, real or personal, which constitutes or is derived
from proceeds traceable to the offense(s) of conviction. Notice is further given that, upon
conviction, the United States intends to seek a judgment against each defendant for a sum of money
representing the property described in this paragraph, as applicable to each defendant (to be offset
53. T h e grand jury finds probable cause to believe that the property subject to forfeiture by
PAUL J. MANAFORT, JR., includes, but is not limited to, the following listed assets:
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a. The r eal property and premises commonly known as 377 Union Street, Brooklyn,
New York, 11231 (Block 429, Lot 65), including all appurtenances, improvements, and
b. The r eal property and premises commonly known as 29 Howard Street, 44D, New
York, New Y o rk, 1 0013 (Block 209, Lo t 1 104), including all a ppurtenances,
d. The r eal property and premises commonly known as 174 Jobs Lane, Water Mill,
New York 11976, including all appurtenances, improvements, and attachments thereon,
Substitute Assets
54, I f any of the property described above as being subject to forfeiture, as a result of any act or
e. has been commingled with other property that cannot be subdivided without
difficulty;
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it is thc intent of the United States of America, pursuant to I'itic 18. United States Code, Section
982(h) and 1'itIe 28, United States Code, Section 246I (c), incorporating 'I itle 2 I, United States
Code, Section 853, h> seek R>rl'eiture r>I'uny other prope>ty of said dcfcndanl.
Robe>t S. Mueller, I I I
Special Counsel
Department ol.lustice
A T'RUE BILL.
o>' per>s(>n
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